Lecturer Profile: Yuya Furuta, Partner Attorney at OneAsia Law Office

When you think of legal hurdles in Los Angeles, your mind probably goes to the gridlock on the 405 or the labyrinthine zoning laws of the City of Council districts. But for a significant portion of our community—particularly those with roots in Southeast Asia—there is a far more complex tangle to unravel: the intersection of international inheritance law. It is a quiet, often stressful struggle that happens behind closed doors in neighborhoods from Filipino Town to the suburbs of the San Fernando Valley, where families find themselves caught between the legal mandates of two different worlds.

The recent focus on international inheritance basics, specifically regarding the Philippines, highlights a critical gap in global legal literacy. While a seminar hosted by the Tsuji-Hongo Tax Corporation might seem like a distant event occurring in Japan, the core issues it addresses are visceral for anyone in Southern California managing assets across borders. The complexities of succession—who gets what, how it is taxed, and which country’s laws take precedence—can turn a family’s legacy into a decades-long legal battle if not handled with surgical precision.

Navigating the Cross-Border Legal Labyrinth

The technicality of international inheritance is not just about who is named in a will; it is about the conflict of laws. When a person passes away leaving property in both the United States and the Philippines, the executors are often blindsided by the fact that the Philippines follows a civil law tradition influenced by Spanish law, which differs fundamentally from the common law system we use here in California. This is where the expertise of specialized practitioners becomes indispensable.

Take, for example, the work of Yuya Furuta, a partner at the One Asia Law Office in their Osaka office. As a lawyer registered with the Osaka Bar Association (registration number 049790) since 2013, Furuta brings over a decade of experience to the table. His role in explaining the foundations of Philippine inheritance law underscores a growing trend: the need for “bridge” lawyers who can navigate the specificities of Asian legal frameworks while communicating those needs to international clients. The One Asia Law Office operates as a hub for these complex transitions, ensuring that the legal requirements of one jurisdiction do not inadvertently trigger a crisis in another.

For a resident of Los Angeles, this means understanding that a will drafted in a local office in Century City might not be automatically recognized or sufficient for the transfer of land or assets in the Philippines. The process often requires a level of coordination that spans continents, involving the Japan Federation of Bar Associations (JFBA) or similar regulatory bodies to verify credentials and ensure that the legal strategies employed are compliant with both local and foreign statutes. You can learn more about these complexities by exploring our guide on international legal coordination.

The Hidden Friction of International Succession

The real friction in these cases usually arises from “forced heirship” rules, which are common in civil law jurisdictions like the Philippines but largely absent in California. In the US, you generally have the freedom to disinherit heirs or exit your estate to whoever you choose. However, in the Philippines, the law often mandates that a certain portion of the estate must go to “compulsory heirs.”

When these two philosophies collide, the result is often a legal stalemate. If an estate is managed solely through the lens of California law, the heirs in the Philippines may find it impossible to register the title of a property or access bank accounts. Conversely, following only the foreign law might lead to tax inefficiencies or disputes among the US-based beneficiaries. This is why the “macro” approach—looking at the global picture before diving into the “micro” local filings—is the only way to ensure a smooth transition of wealth.

Local Solutions for Global Legacies

Given my background in analyzing regional professional services, the Filipino-American community in Los Angeles needs a very specific trifecta of support. If you are dealing with assets in the Philippines while residing in LA County, you cannot rely on a general practitioner. You need a team that understands the “ancillary probate” process—the legal proceeding used to handle assets in a second jurisdiction.

If this trend impacts your family’s financial future, here are the three types of local professionals Make sure to seek out in the Los Angeles area to complement your international counsel:

International Estate Planning Attorneys

Do not settle for a standard probate lawyer. You need a specialist who has a proven track record with “cross-border succession.” When interviewing, ask specifically if they have experience with the Hague Apostille Convention, which is essential for making US documents legally valid in the Philippines. They should be able to coordinate directly with firms like One Asia Law Office to ensure your California trust doesn’t conflict with foreign compulsory heirship laws.

Cross-Border Tax Strategists (CPAs)

Inheritance isn’t just about ownership; it’s about the tax bill. You need a CPA who understands both the US Internal Revenue Service (IRS) requirements and the specific estate taxes of the Philippines. Gaze for professionals who are well-versed in FATCA (Foreign Account Tax Compliance Act) reporting. A failure to report foreign assets can lead to penalties that dwarf the value of the inheritance itself.

Certified Legal Translators and Notaries

The paperwork involved in international inheritance is staggering. From death certificates to affidavits of self-adjudication, every document must be translated and notarized to a standard that will be accepted by the Philippine consulate or the local courts in Manila or Cebu. Ensure your provider is certified by a recognized professional body and has experience with legal terminology in both English and the target language to avoid clerical errors that could delay probate for years.

Navigating these waters requires patience and a willingness to look beyond the borders of the Southland. Whether you are coordinating with an expert like Yuya Furuta in Osaka or searching for a specialist in Downtown LA, the goal is the same: protecting the legacy you’ve worked a lifetime to build. You can find more specialized advice in our section on cross-border asset management.

Ready to find trusted professionals? Browse our complete directory of top-rated estate planning experts in the Los Angeles area today.